Chhattisgarh High Court reaffirms that while conviction under Sections 279 and 304-A IPC must be sustained when supported by evidence, the sentence can be reduced to the period already undergone where mitigating factors exist such as youth, lack of criminal history, and genuine accident circumstances. The ruling follows existing precedent and serves as binding authority within the state for sentencing discretion in motor vehicle accident cases.
Summary
| Category | Data |
|---|---|
| Case Name | CRR/808/2016 of Godhan Koma Vs State Of Chhattisgarh |
| CNR | CGHC010291622016 |
| Date of Registration | 26-08-2016 |
| Decision Date | 16-10-2025 |
| Disposal Nature | PARTLY ALLOWED |
| Judgment Author | Hon’ble Shri Justice Radhakishan Agrawal |
| Court | High Court of Chhattisgarh at Bilaspur |
| Precedent Value | Binding on subordinate courts in Chhattisgarh |
| Overrules / Affirms |
|
| Type of Law | Criminal Law (Sentencing under IPC Sections 279 and 304-A) |
| Questions of Law | Whether in cases of conviction under Sections 279 and 304-A IPC, sentencing can be reduced to the period already undergone based on mitigating factors, even when conviction is affirmed. |
| Ratio Decidendi |
The High Court held that while conviction under Sections 279 and 304-A IPC is proper where supported by cogent evidence, sentencing must consider individual circumstances. Mitigating factors such as the youth of the accused, no prior criminal record, a genuine accident caused by mechanical failure, the period of trial endured, and prompt post-accident assistance justify reducing the sentence to the time already spent in custody. The conviction and fine remain undisturbed, but further imprisonment is unnecessary to serve the ends of justice. |
| Judgments Relied Upon | Krishna Kumar Chauhan Vs. State of Chhattisgarh (CRR No.1109/2015, decided on 21.11.2024) |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | The Court considered the factual matrix (age, criminal antecedents, deposit of fine, nature of accident as per Mechanical Examination Report) and precedent on reduction of sentence. |
| Facts as Summarised by the Court |
On 25.09.2015, the applicant, aged 21, drove a TATA ACE vehicle that struck Subhash Dev Reddy, resulting in fatal injuries. The applicant had no prior criminal record, remained in jail for 21 days, faced trial for over 10 years, deposited the fine, and took the victim to hospital. The accident was corroborated as caused by brake failure in the mechanical report (Ex.P-12). |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Chhattisgarh |
| Persuasive For | Other High Courts, especially in similar factual circumstances |
| Follows | Krishna Kumar Chauhan v. State of Chhattisgarh (CRR No.1109/2015) |
What’s New / What Lawyers Should Note
- The High Court explicitly affirmed that while conviction under Sections 279 and 304-A IPC should be upheld on proper evidence, sentencing is open to judicial discretion considering mitigating factors.
- Practitioners can cite the principle that youth, clean antecedents, long pendency of trial, mechanical failure, post-accident conduct, and payment of fine can justify reduction of sentence to time already served.
- Reliance on mechanical examination reports showing lack of malice or intentionality in accidents can be critical in sentencing submissions.
- The ruling follows and reinforces the precedent set in Krishna Kumar Chauhan v. State of Chhattisgarh.
Summary of Legal Reasoning
- The Court surveyed the evidence presented at trial and on appeal, particularly focusing on witness testimony and the mechanical examination report, which attributed the accident to brake failure rather than malicious or grossly negligent conduct.
- The judgment referenced and applied the precedent in Krishna Kumar Chauhan v. State of Chhattisgarh, where similar mitigating factors warranted sentence reduction.
- The High Court reasoned that lengthy pendency (over ten years), short jail term already undergone, absence of criminal history, payment of fine, and the youth of the accused at the time of the incident constitute adequate grounds for reducing the custodial sentence.
- The Court clarified that the conviction is not in question but the sentence may justly be limited to the period already undergone, upholding the principle of proportionality and individualized sentencing.
- The fine sentence and bail bond requirements were affirmed as per statutory provisions.
Arguments by the Parties
Petitioner
- Did not challenge the conviction but limited the appeal to quantum of sentence.
- Emphasized mitigating factors: 21 days already spent in jail, over 10 years in litigation, no criminal antecedents, fine already paid, age (21 years) at the time of accident, and occurrence of accident due to proven sudden brake failure.
- Highlighted post-accident conduct: applicant transported the injured to hospital.
- Cited Krishna Kumar Chauhan v. State of Chhattisgarh for reduction of sentence.
Respondent (State)
- Supported the decisions of the lower courts and opposed any reduction in sentence.
Factual Background
On 25.09.2015, a fatal road accident occurred in which the applicant, then aged 21 and driving a TATA ACE vehicle, struck Subhash Dev Reddy, who later died due to the injuries sustained. The case was investigated and tried under Sections 279 and 304-A IPC. The applicant had no criminal history, spent 21 days in custody, and had already deposited his fine. Both the trial and appellate courts found him guilty and sentenced him to imprisonment and fine. The revision before the High Court was confined to seeking leniency in sentencing due to mitigating circumstances, including mechanical failure as the cause of the accident.
Statutory Analysis
- Sections 279 and 304-A IPC: The Court reaffirmed that these provisions criminalize rash/negligent driving and causing death by such driving, respectively.
- No expansive or narrow interpretation was discussed, but the Court stressed that these sections require evidence of negligence.
- Sentencing provisions were interpreted to permit judicial discretion based on individual circumstances for proportional punishment.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinions are recorded in this judgment.
Procedural Innovations
- The Court explicitly ordered that the bail bond shall remain in force for six months in line with Section 481 of the BNSS, 2023, standardizing the procedural approach for post-conviction bail.
Alert Indicators
- ✔ Precedent Followed – The judgment follows and reinforces prior High Court precedent regarding reduction of sentence in cases under Sections 279 and 304-A IPC based on individualized mitigating circumstances.